This is a complex civil action for RICO remedies
authorized by the federal statutes at 18 U.S.C. 1961et
seq.;for declaratory and
injunctive relief;for actual,
consequential and exemplary damages;and for all other relief which this honorable Superior Court deems just
and proper under all circumstances which have occasioned this Initial
COMPLAINT.See 18 U.S.C. §§1964(a) and (c)
(“Civil RICO”).

The
primary cause of this action is a widespread criminal enterprise engaged
in a pattern of racketeering activity across State lines, and a
conspiracy to engage in racketeering activity involving numerous RICO
predicate acts during the past ten (10) calendar years.

Other
RICO predicate acts, although appearing to be isolated events, were
actually part of the overall conspiracy and pattern of racketeering activity
alleged herein, e.g. mail fraud and bank fraud.See 18 U.S.C. §§1341 and 1344, respectively.

The
primary objective of the racketeering enterprise has been to inflict
severe and sustained economic hardship upon Plaintiff, with the intent of
impairing, obstructing, preventing and discouraging Plaintiff from writing,
publishing, investigating and conducting judicial activism as a qualified Private Attorney General.

This honorable Superior
Court has original jurisdiction pursuant to the civil RICO remedies at 18 U.S.C. 1964, and
the holdings of the U.S. Supreme Court in Tafflin v. Levitt, 493
U.S. 455 (1990), and the
U.S. Court of Appeals for the Ninth Circuit in Lou v. Belzberg, 834 F.2d
730, hn. 4 (9th Cir. 1987) (California State courts have concurrent
jurisdiction of civil RICO claims).

On August 1, 2001 A.D.,
Plaintiff filed a federal lawsuit in the District Court of the United States
for the Eastern Judicial District of California (“DCUS”),
in Sacramento, alleging five separate counts:

In anticipation of
probable obstruction by federal officers and employees of the United States
District Court in Sacramento (“USDC”),
Plaintiff reserved COUNT SIX: Civil RICO for adjudication by this Superior
Court of California.This action is
COUNT SIX+, in effect.

The obstruction
anticipated by Plaintiff has now occurred in that federal case, in part by
impersonation of Article III
federal judges in violation of 18 U.S.C. 912 (a
federal felony) and of numerous Ninth Circuit precedents
in re civil jurisdiction of U.S. magistrate judges.

As such, federal officers
and employees are now among the probable causes that threaten further
continuation of the severe economic hardship and other wrongs described above.

It is also apparent to
Plaintiff, who hereby makes a formal offer to prove, that the instant action
should not be removed into the Article IIIDCUS because the DCUS is presently vacant, nor
should it ever be removed into the Article IVUSDC because of demonstrable
bias and prejudice among officers and employees of the USDC.

Exhibits M‑2 et
seq. will be held in reserve for important documents that are expected to
issue from the federal case at future times and places as yet unknown to
Plaintiff.

Thus, Exhibits lettered A
thru M are reserved for the federal case supra;Exhibits lettered N thru Z are reserved for
this case.

Exhibits N‑1 thru N‑138 inclusive correspond
in sequence to the numbered entries in the Table of Contents at Exhibit M‑1, now frozen to fix the
correspondence between those entries and Exhibit numbers.

This Court is encouraged
to use computers to access all pleadings and electronic evidence already
published in the Supreme Law Library.

Plaintiff now formally
incorporates Exhibits A‑1 thru and including N‑138 by reference, as
if all were set forth fully here.

Particular attention of
this honorable Court is now drawn to Exhibits L‑6, D‑46
and D‑47.

Exhibit L‑6 is
the legislative history of the Anticounterfeiting Consumer Protection Act of
1996 (“ACPA”),
reproduced from the House Congressional Record dated June 4, 1996, 110 Stat.
1386, July 2, 1996.

The ACPA is particularly
relevant to the instant case, because it elevated copyright and trademark
infringement to the status of RICO predicate acts, and cited superb reasons for
doing so.

An excellent discussion
of the legal implications of the ACPA, in the context
of other applicable federal laws, can be seen in Exhibit N‑124: LETTER TO JON MUMMOLO, Washington Square News,
Nov. 9, 2002.

Exhibit D‑46
is a partial list of Documented
Retaliations which Plaintiff had suffered prior to the date on which
the federal case was first filed (August 1, 2001 A.D.)

Exhibit D‑47
is a subset of those Documented Retaliations which also qualify as one or more
of the RICO Predicate Acts that
are itemized at 18 U.S.C. §§1961(1)(B),
(1)(D), and (5).

Plaintiff now
testifies that the partial list of acts and events now documented in Exhibits D‑46
and D‑47 constitutes probable cause for granting all relief requested infra
in the instant COMPLAINT.

Moreover, further acts and
events occurred after August 1, 2001, which also qualify as RICO
predicate acts that constitute further probable causes for all the
relief requested infra.

For example, Plaintiff
herein alleges that obstruction of justice did in fact occur whenever
Plaintiff was deprived of specific relief from the federal district courts in
Sacramento, California.

Plaintiff now re-alleges
each and every allegation as set forth above, and hereby incorporates same by
reference, as if all were set forth fully herein.Substance prevails over form.

At various times and
places partially enumerated in Plaintiff’s documentary material, all Defendants
did acquire and/or maintain, directly or indirectly, an interest in or control
of a RICO enterprise of individuals who were associated in fact and who
did engage in, and whose activities did affect, interstate and foreign
commerce, all in violation of 18 U.S.C. §§1961(4), (5), (9),
and 1962(b).

During the ten (10)
calendar years preceding March 1, 2003 A.D., all Defendants did
cooperate jointly and severally in the commission of two (2) or more of the
RICO predicate acts that are itemized in the RICO laws at 18 U.S.C. §§1961(1)(A) and (B),
and did so in violation of the RICO law at 18 U.S.C. 1962(b)
(Prohibited activities).

Plaintiff further alleges
that all Defendants did commit two (2) or more of the offenses itemized above
in a manner which they calculated and premeditated intentionally to threaten
continuity, i.e. a continuing threat of their respective racketeering
activities, also in violation of the RICO law at 18 U.S.C. 1962(b) supra.

Pursuant to the original
Statutes at Large, the RICO laws itemized above are to be liberally
construed by this honorable Court.Said
construction rule was never codified in Title 18 of the United States
Code, however.See 84 Stat. 947, Sec.
904, Oct. 15, 1970.

Plaintiff now re-alleges
each and every allegation as set forth above, and hereby incorporates same by
reference, as if all were set forth fully herein.Substance prevails over form.

At various times and
places partially enumerated in Plaintiff’s documentary material, all
Defendants did associate with a RICO enterprise of individuals who were
associated in fact and who engaged in, and whose activities did affect,
interstate and foreign commerce.

Likewise, all Defendants
did conduct and/or participate, either directly or indirectly, in the conduct
of the affairs of said RICO enterprise through a pattern of
racketeering activity, all in violation of 18 U.S.C. §§1961(4), (5), (9),
and 1962(c).

During the ten (10)
calendar years preceding March 1, 2003 A.D., all Defendants did
cooperate jointly and severally in the commission of two (2) or more of the
RICO predicate acts that are itemized in the RICO laws at 18 U.S.C. §§1961(1)(A) and (B),
and did so in violation of the RICO law at 18 U.S.C. 1962(c)
(Prohibited activities).

Plaintiff further alleges
that all Defendants did commit two (2) or more of the offenses itemized above
in a manner which they calculated and premeditated intentionally to threaten
continuity, i.e. a continuing threat of their respective racketeering
activities, also in violation of the RICO law at 18 U.S.C. 1962(c) supra.

Pursuant to 84 Stat. 947,
Sec. 904, Oct. 15, 1970, the RICO laws itemized above are to be liberally
construed by this honorable Court.Said
construction rule was never codified in Title 18 of the United States Code,
however. Respondeat superior (as
explained above).

Plaintiff now re-alleges
each and every allegation as set forth above, and hereby incorporates same by
reference, as if all were set forth fully herein.Substance prevails over form.

At various times and
places partially enumerated in Plaintiff’s documentary material, all
Defendants did conspire to acquire and maintain an interest in a RICO enterprise
engaged in a pattern of racketeering activity, in violation of 18 U.S.C.
§§1962(b) and (d).

At various times and
places partially enumerated in Plaintiff’s documentary material, all
Defendants did also conspire to conduct and participate in said RICO enterprise
through a pattern of racketeering activity, in violation of 18 U.S.C. §§1962(c) and (d).

During the ten (10)
calendar years preceding March 1, 2003 A.D., all Defendants did
cooperate jointly and severally in the commission of two (2) or more of the
predicate acts that are itemized at 18 U.S.C. §§1961(1)(A) and (B),
in violation of 18
U.S.C. 1962(d).

Plaintiff further alleges
that all Defendants did commit two (2) or more of the offenses itemized above
in a manner which they calculated and premeditated intentionally to threaten
continuity, i.e. a continuing threat of their respective racketeering
activities, also in violation of 18 U.S.C. 1962(d)
(Prohibited activities supra).

Pursuant to 84 Stat. 947,
Sec. 904, Oct. 15, 1970, the RICO laws itemized above are to be liberally
construed by this honorable Court.Said
construction rule was never codified in Title 18 of the United States Code,
however.Respondeat superior (as
explained above).

1.That this Court liberally construe the RICO laws and thereby
find that all Defendants, both jointly and severally, have acquired and
maintained, both directly and indirectly, an interest in and/or control of a
RICO enterprise of persons and of other individuals who were
associated in fact, all of whom engaged in, and whose activities did affect, interstate
and foreign commerce in violation of 18 U.S.C. 1962(b)
(Prohibited activities).

2.That all
Defendants and all their directors, officers, employees, agents, servants and
all other persons in active concert or in participation with them, be
enjoined temporarily during pendency of this action, and permanently
thereafter, from acquiring or maintaining, whether directly or indirectly, any
interest in or control of any RICO enterprise of persons, or of
other individuals associated in fact, who are engaged in, or whose activities
do affect, interstate or foreign commerce.

3.That all
Defendants and all of their directors, officers, employees, agents, servants
and all other persons in active concert or in participation with them,
be enjoined temporarily during pendency of this action, and permanently
thereafter, from committing any more predicate acts in furtherance of the RICO enterprise
alleged in COUNT ONEsupra.

4.That all Defendants
be required to account for all gains, profits, and advantages derived from
their several acts of racketeering activity in violation of 18 U.S.C. 1962(b) and
from all other violation(s) of applicable State and federal law(s).

5.That judgment be
entered for Plaintiff and against all Defendants for Plaintiff’s actual
damages, and for any gains, profits, or advantages attributable to all
violations of 18
U.S.C. 1962(b), according to the best available proof.

6.That all
Defendants pay to Plaintiff treble (triple) damages, under authority of 18 U.S.C. 1964(c),
for any gains, profits, or advantages attributable to all violations of 18 U.S.C. 1962(b),
according to the best available proof.

7.That all Defendants
pay to Plaintiff all damages sustained by Plaintiff in consequence of
Defendants’ several violations of 18 U.S.C. 1962(b),
according to the best available proof.

8.That all Defendants
pay to Plaintiff His costs of the lawsuit incurred herein including, but not
limited to, all necessary research, all non‑judicial enforcement and all
reasonable counsel’s fees, at a minimum of $150.00 per hour worked (Plaintiff’s
standard professional rate at start of this action).

9.That all damages
caused by all Defendants, and all gains, profits, and advantages derived by all
Defendants, from their several acts of racketeering in violation of 18 U.S.C. 1962(b) and
from all other violation(s) of applicable State and federal law(s), be deemed
to be held in constructive trust, legally foreign with respect to the federal
zone [sic], for the benefit of
Plaintiff, His heirs and assigns.

10.That
Plaintiff have such other and further relief as this Court deems just and
proper, under the circumstances of this action.

1.That this Court liberally construe the RICO laws and thereby
find that all Defendants have associated with a RICO enterprise of persons
and of other individuals who were associated in fact, all of whom did engage
in, and whose activities did affect, interstate and foreign commerce in
violation of the RICO law at 18 U.S.C. 1962(c)
(Prohibited activities).

2.That this Court liberally construe the RICO laws and thereby
find that all Defendants have conducted and/or participated, directly or
indirectly, in the affairs of said RICO enterprise through a pattern
of racketeering activity in violation of the RICO laws at 18 U.S.C. §§1961(5) (“pattern”
defined) and 1962(c)
supra.

3.That all Defendants and all of their directors, officers,
employees, agents, servants and all other persons in active concert or
in participation with them, be enjoined temporarily during pendency of
this action, and permanently thereafter, from associating with any RICO enterprise
of persons, or of other individuals associated in fact, who do engage
in, or whose activities do affect, interstate and foreign commerce.

4.That all Defendants and all of their directors, officers,
employees, agents, servants and all other persons in active concert or
in participation with them, be enjoined temporarily during pendency of
this action, and permanently thereafter, from conducting or
participating, either directly or indirectly, in the conduct of the affairs of
any RICO enterprise through a pattern of racketeering activity in
violation of the RICO laws at 18 U.S.C. §§1961(5) and 1962(c) supra.

5.That all
Defendants and all of their directors, officers, employees, agents, servants
and all other persons in active concert or in participation with them,
be enjoined temporarily during pendency of this action, and permanently
thereafter, from committing any more predicate acts in furtherance of the RICO enterprise
alleged in COUNT TWOsupra.

6.That all Defendants
be required to account for all gains, profits, and advantages derived from
their several acts of racketeering in violation of 18 U.S.C. 1962(c) supra
and from all other violation(s) of applicable State and federal law(s).

7.That judgment be
entered for Plaintiff and against all Defendants for Plaintiff’s actual
damages, and for any gains, profits, or advantages attributable to all
violations of 18
U.S.C. 1962(c) supra, according to the best available proof.

8.That all
Defendants pay to Plaintiff treble (triple) damages, under authority of 18 U.S.C. 1964(c),
for any gains, profits, or advantages attributable to all violations of 18 U.S.C. 1962(c)
supra, according to the best available proof.

9.That all Defendants
pay to Plaintiff all damages sustained by Plaintiff in consequence of
Defendants’ several violations of 18 U.S.C. 1962(c)
supra, according to the best available proof.

10.That all Defendants
pay to Plaintiff His costs of the lawsuit incurred herein including, but not
limited to, all necessary research, all non‑judicial enforcement and all
reasonable counsel’s fees, at a minimum of $150.00 per hour worked (Plaintiff’s
standard professional rate at start of this action).

11.That all damages
caused by all Defendants, and all gains, profits, and advantages derived by all
Defendants, from their several acts of racketeering in violation of 18 U.S.C. 1962(c) supra
and from all other violation(s) of applicable State and federal law(s), be deemed
to be held in constructive trust, legally foreign with respect to the federal
zone [sic], for the benefit of
Plaintiff, His heirs and assigns.

12.That
Plaintiff have such other and further relief as this Court deems just and
proper, under the full range of relevant circumstances which have occasioned
the instant action.

1.That this Court liberally construe the RICO laws and thereby
find that all Defendants have conspired to acquire and maintain an interest in,
and/or conspired to acquire and maintain control of, a RICO enterprise
engaged in a pattern of racketeering activity in violation of 18 U.S.C. §§1961(5), 1962(b) and (d) supra.

2.That this Court liberally construe the RICO laws and thereby
find that all Defendants have conspired to conduct and participate in said RICO
enterprise through a pattern of racketeering activity in violation
of 18 U.S.C. §§1961(5), 1962(c) and (d) supra.

3.That all Defendants and all their directors, officers,
employees, agents, servants and all other persons in active concert or
in participation with them, be enjoined temporarily during pendency of
this action, and permanently thereafter, from conspiring to acquire or
maintain an interest in, or control of, any RICO enterprise that engages
in a pattern of racketeering activity in violation of 18 U.S.C. §§1961(5), 1962(b) and (d) supra.

4.That all Defendants and all their directors, officers,
employees, agents, servants and all other persons in active concert or
in participation with them, be enjoined temporarily during pendency of
this action, and permanently thereafter, from conspiring to conduct,
participate in, or benefit in any manner from any RICO enterprise
through a pattern of racketeering activity in violation of 18 U.S.C. §§1961(5), 1962(c) and (d) supra.

5.That all
Defendants and all their directors, officers, employees, agents, servants and
all other persons in active concert or in participation with them, be
enjoined temporarily during pendency of this action, and permanently
thereafter, from committing any more predicate acts in furtherance of the RICO enterprise
alleged in COUNT THREEsupra.

6.That all Defendants
be required to account for all gains, profits, and advantages derived from
their several acts of racketeering in violation of 18 U.S.C. 1962(d) supra
and from all other violation(s) of applicable State and federal law(s).

7.That judgment be
entered for Plaintiff and against all Defendants for Plaintiff’s actual
damages, and for any gains, profits, or advantages attributable to all
violations of 18
U.S.C. 1962(d) supra, according to the best available proof.

8.That all
Defendants pay to Plaintiff treble (triple) damages, under authority of 18 U.S.C. 1964(c),
for any gains, profits, or advantages attributable to all violations of 18 U.S.C. 1962(d) supra,
according to the best available proof.

9.That all Defendants
pay to Plaintiff all damages sustained by Plaintiff in consequence of
Defendants’ several violations of 18 U.S.C. 1962(d) supra,
according to the best available proof.

10.That all Defendants
pay to Plaintiff His costs of the lawsuit incurred herein including, but not
limited to, all necessary research, all non‑judicial enforcement, and all
reasonable counsel’s fees, at a minimum of $150.00 per hour worked (Plaintiff’s
standard professional rate at start of this action).

11.That all damages
caused by all Defendants, and all gains, profits, and advantages derived by all
Defendants, from their several acts of racketeering in violation of 18 U.S.C. 1962(d) supra
and from all other violation(s) of applicable State and federal law(s), be
deemed to be held in constructive trust, legally foreign with respect to the
federal zone [sic], for the benefit
of Plaintiff, His heirs and assigns.

12.That
Plaintiff have such other and further relief as this Court deems just and
proper, under the full range of relevant circumstances which have occasioned
the instant action.

I,
Paul Andrew Mitchell, Sui Juris, Plaintiff in the above entitled action,
hereby verify under penalty of perjury, under the laws of the United States of
America, without the “United States” (federal government), that the above
statement of facts and laws is true and correct, according to the best of My
current information, knowledge, and belief, so help me God, pursuant to 28 U.S.C. 1746(1).See the Supremacy Clause in the
Constitution for the United States of America, as lawfully amended (hereinafter
“U.S. Constitution”).